Anti-bribery & corruption

The Group has a well-established anti-corruption policy and associated procedures. Specifically, these cover bribery and corruption, conflicts of interest, gifts and hospitality, and facilitation payments. A number of other policies within the Operational Framework also address bribery and corruption risks in areas such as finance, political donations and lobbying, charitable donations and offset.
 
Our detailed anti-corruption procedures are incorporated within our Bribery Act Compliance Manual (“BACM”), which is updated on a regular basis, and includes requirements for:

  • each business to routinely conduct informed bribery risk assessments as part of normal operating procedures, to determine the nature and extent of the Group’s exposure to potential internal and external risks of bribery and corruption on its behalf by persons associated with it;
  • approval of the appointment of all sales partners and other third party advisers, which in all circumstances requires the completion of risk-based due diligence, appropriate management approvals, use of standard form contracts, and ongoing monitoring and review;
  • risk-based anti-corruption processes for the engagement of service providers and suppliers;
  • regular mandatory training on BACM and its application to their role for Board members, management, supervisors and all employees working within commercial, sales and marketing, finance, procurement, and human resource functions;
  • approval of the giving and receiving of reasonable, proportionate and appropriate gifts and hospitality in the normal course of business; and
  • proper identification, disclosure and management of potential or actual conflicts of interest.

A BACM “Pocket Guide” is issued to all employees across the Group, providing an overview of our anti-corruption policies and the requirements of the detailed manual. 

All businesses are required to complete a BACM Compliance Certificate on a biannual basis, confirming that all policies and procedures within BACM have been complied with and providing supporting documentation. We recognise that the appointment of third party sales partners in our routes to market can present particular bribery and corruption risks, and we therefore implement enhanced anti-corruption procedures for the engagement of sales partners where it is necessary to use them by mandating:

  • restrictions on the number of sales partners to be engaged in each territory;
  • the preparation of a full business case to justify the appointment of all new third party sales partners, including a two-stage bribery risk assessment incorporating the requisite level of risk-based due diligence, which must be approved by the Group Chief Executive before the sales partner is appointed;
  • a full annual reappointment process for all retained sales partners, including recommissioning of the appropriate risk-based due diligence and resubmission of a full business case for approval by the Group Chief Executive; and
  • increased reporting requirements for all payments made to third party sales partners and higher risk service providers.

Our anti-corruption processes are managed within the Chemring Compliance Portal, which provides consistency of application across the Group. The portal was introduced in late 2020. We have transitioned all sales partners to the new system, and will be transitioning service providers and higher-risk suppliers during 2021. The system allows us to monitor third parties on a continuous basis and also incorporates a module for employees to seek online approval for gifts and hospitality.

Relevant employees (including members of the Board) receive updated training on BACM on a regular basis. The Ethics & Compliance Committee reviews BACM compliance as a standing agenda item at every meeting and our processes are reviewed by PwC as part of our internal audit programme.  

Anti-facilitation of tax evasion

Chemring adopts a zero-tolerance approach to the facilitation of tax evasion, whether under UK law or under the law of any foreign country.

None of our businesses reside in countries considered as partially compliant or non-compliant according to the OECD tax transparency report and/or considered to be Offshore Financial Centres by the IMF or blacklisted or grey listed by the EU in February 2020.

Commercial

Our Commercial Policy sets out the procedures required to be adopted by all businesses to ensure that appropriate commercial practices and controls are implemented, and that commercial and contractual risks are properly identified and adequately mitigated. The objectives of the policy are to ensure that customer bids and proposals are prepared, and contracts with third parties are negotiated, administered and executed, on a basis which will enable the contracting parties to satisfy their commercial and legal obligations, whilst delivering the requisite levels of return for the business and minimising potential liabilities.

Community Investment

Chemring recognises that our employees and businesses have an important role to play in their local communities and in supporting broader charitable activities. Our Community Investment Policy sets out our approach to employee involvement in charitable activities, and our policy on donations to charities and other not-for-profit organisations.

Competition/anti-trust

Chemring aims to compete vigorously but fairly in all of the markets in which we operate, and we are committed to complying with competition and anti-trust laws. The Company will not engage in anti-competitive behaviour and will not tolerate such behaviour from our employees or any third parties acting on our behalf. The Competition Law Compliance Policy provides an overview of the main competition and anti-trust laws that could affect our business, and sets out procedures and guidelines which must be followed when dealing with matters to which competition or anti-trust laws may apply.

Conflicts of interest

Conflicts of interests can arise where an employee’s interests conflict with, or might appear to conflict with, those of Chemring, as a consequence of their personal relationships with customers, business partners, suppliers or competitors. Such conflicts may impair the ability of an employee to make objective and unbiaised business decisions in the interests of the Company. The Conflicts of Interest Policy sets out Chemring’s requirements in relation to the disclosure and proper management of potential conflicts of interest.

All businesses are required to maintain a Conflicts of Interest Register, a copy of which is required to be submitted with their BACM Compliance Certificate on a biannual basis.

Export control

Chemring complies fully with all export control laws applicable to the countries in which we do business. All businesses are required to maintain export control procedures to ensure that all requisite approvals are obtained for the transfer of products, services, technology and data from one country to another, and to implement systems which will detect export control violations promptly if they do occur.

Gifts and hospitality

Bona fide hospitality, promotional or other business expenditure which seeks to improve the image of our businesses, to better present our products and services, and to foster relationships with our customers and suppliers, is recognised as an established and important part of doing business. However, if the giving or receiving of a gift or hospitality is intended to influence the outcome of a contractual or material transaction, or to induce or reward improper behaviour on the part of the recipient, it may constitute an illegal bribe.

All employees are required to seek approval for gifts and hospitality through the Chemring Compliance Portal.

Intellectual property

Chemring is committed to protecting its own intellectual property, such as information, processes, and technology, from infringement by others. The Company is also committed to respecting the intellectual property of others. The Intellectual Property Policy and our Code of Conduct set out standards and behaviours expected of all employees in the management of intellectual property.

Offset

The Company is committed to ensuring that any offset activity undertaken by our businesses, or on their behalf, complies fully with all applicable laws and regulations, our Code of Conduct and our Bribery Act Compliance Manual. The Offset Policy sets out the requirements for approval, resourcing and recording of offset transactions and obligations.

Personal data protection

Chemring is committed to being transparent about how it collects and uses the personal data of employees and third parties, and to meeting its data protection obligations. Our Data Protection and Privacy Policy sets out the organisation’s commitment to data protection and the principles that will be adopted in handling and processing personal data. The policy details the ways in which we may obtain, use, hold, transfer and otherwise process personal data.

Political donations and lobbying

The Political Donations and Lobbying Policy provides guidelines on political and lobbying activities undertaken by our businesses and our employees, which must be in full compliance with all applicable laws and regulations, our Code of Conduct and our Bribery Act Compliance Manual.

Chemring does not make donations or contributions to any political campaign, potential candidate or any of their associated organisations.

Share dealing and inside information

It is an offence to deal in Chemring shares, or related securities, when in possession of “inside information” concerning the Company - this is broadly defined as information which has not yet been made public and which, if it were made public, would be likely to have a significant impact on the Company’s share price. Consequently, there are certain periods during which employees (and their immediate family) must not deal in the Company’s shares. All dealings in the Company’s shares must comply with the Share Dealing Policy.

The Company has also established procedures to ensure that information which may constitute inside information is identified and reported promptly, in order to ensure that the Company is able to release such information to the public in accordance with its legal obligations. These procedures are detailed in the Inside Information Policy.

Supply chain

Supply chain excellence is one of the foundation blocks of smooth efficient manufacturing. Our supply chain functions must ensure we work in partnership with our suppliers in order to provide a professional sustainable service of high quality, which will ensure the delivery of materials on time, in full. The supply chain functions must ensure the delivery of feasible manufacturing plans in co-ordination with other stakeholders. The Supply Chain Policy sets out Chemring’s minimum requirements for supply chain management and procurement.

Code of Conduct

The Code of Conduct, which sits alongside our Operational Framework, embraces our fundamental values of Safety, Excellence and Innovation. It provides direction to all employees on legal, ethical and risk issues that they may encounter in their day-to-day activities.

All employees and all third parties who act on the Group’s behalf are required to comply with the Group’s standards of behaviour and business conduct, as set out within the Code, and applicable laws and regulations in all of the countries in which the Group operates. All employees, current and new, are provided with a copy of the Code of Conduct, and receive training on its application to their role within the business.

Our Code of Conduct can be found at the bottom of this page.

Whistleblowing

Our Chemring culture embraces transparency and openness, and we encourage all employees to speak up if they have any concerns. We have a whistleblowing policy and associated procedures in place which enable all employees to raise concerns, in confidence, about possible improprieties or wrongdoing within the business, without fear of reprisal or retaliation. Employees are able to raise issues by contacting our 24-hour ethics reporting service by phone, email or an external website. All issues reported by employees are taken seriously and investigated appropriately in a confidential manner.

The Board has overall responsibility for the Group’s whistleblowing arrangements. The Ethics & Compliance Committee has oversight of the arrangements, and is briefed on all significant reports received and the findings of subsequent investigations.

Human rights

The Group is committed to respecting human rights in the countries in which we do business. Our Code of Conduct and other applicable policies under the Operational Framework support our commitment to ensuring, as far as we are able, that there is no slavery or human trafficking in any part of our business or in our supply chain. All suppliers are provided with a copy of our Supplier Code of Conduct (link at the bottom of this page), which requires them to adhere to our ethical standards and expectations, including in relation to human rights. We do not knowingly support or do business with any suppliers who are involved in slavery.

A statement of the Group’s compliance with the Modern Slavery Act 2015 can be found at the bottom of this page.

We fully adhere to all relevant government guidelines designed to ensure that our products are not knowingly incorporated into weapons, or other equipment, used for the purposes of terrorism, international repression or the abuse of human rights.

Download the Code of Conduct
Download the Modern Slavery Act Statement
Download the Supplier Code of Conduct